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F
Risks analysis [G4-14]
F.3
Compliance and reputation risk
Atos
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Document de Référence 2016
233
F
Compliance and reputation risk
F.3
Regulatory risks
F.3.1
legal, administrative or regulatory authorizations.
The activities of the Group are in general not subject to specific
concerned.
requirements of this regulation are met by the entities
However, activities related to payments in Europe have been
regulation. A dedicated follow-up is performed to ensure that the
subject since 2011 to the European Payments Institution
Compliance risks
F.3.2
compliance risks. Atos has addressed these areas by way of an
reinforced, resulting in a potentially greater exposure to
In the last few years, Atos’ international presence has been
activities and jurisdictional exposure, such as bribery,
to take into account the compliance risks specific to new
enhancement and refinement of its compliance program in order
sanctions, export control & customs (ECC) regulations.
competition, market abuse, money laundering, international
exposed to Personal Data Protection regulations, which protect
As an employer and as a service provider, Atos is regularly
data protection organization at all levels of its organization to
world. Atos has therefore deployed a strong and coordinated
the identity, privacy and liberties of individuals in the digital
provide training, support and expertise to the operations.
mandatory Atos Rainbow business review for all commercial
respect to key compliance risks has been reinforced in the
Additionally, since 2014, a system of checks and approvals with
unapproved use of Atos goods and services by third parties.
transactions.
corporate solutions in all Atos Business Units and to prevent the
enable a systematic integration of compliance risks in predefined
A wide array of internal policies have been implemented to
Compliance initiatives are further described in section D.4.1.1.
Compliance.
Intellectual property protection
F.3.3
license agreement requests or license requirements under open
and the Group may be subject to infringement claims, cross
The Group’s intellectual property may be challenged or infringed
source.
copyright, trademark, patent, domain name and trade secret
The Group relies on a combination of contractual rights and
property.
invalidate, circumvent, infringe or misappropriate its intellectual
co-owned intangible assets. Third parties may challenge,
laws to establish and protect its proprietary technology and
technology, duplicate its services or design around its intellectual
others, including its competitors, may develop similar
sufficient to permit to conduct its business independently,
While the Group strives to ensure that its intellectual property is
obtain licenses from these third parties (including in the context
intellectual property rights against such parties or may have to
property. In such cases the Group could not assert its
enforceability of its intellectual property rights, trade secrets and
may have to litigate to enforce or determine the scope and
also grant a license under its intellectual property). The Group
of cross license agreements, pursuant to which the Group would
property protection or the inability to obtain third party
resources and may not prove successful. The loss of intellectual
know-how, which is expensive, could cause a diversion of
to freely operate.
intellectual property could harm the Group’s business and ability
implementation of appropriate policies and processes, and a
providing dedicated resources which are entrusted with the
ramifies deeply into operations by means of an Intellectual
management representatives and internal stakeholders and
Committee which convenes on a quarterly basis and gathers top
governance is headed by an intellectual property Steering
Development at Divisions or local level.
Property Managers network active within Research &
strong worldwide patent applications filings campaign. This
the Group are subject to an increase in the number of risks
Due to their complexity, the technology domains addressed by
of specific governance described in the “Atos IP policy” and is
them efficiently, the Group develops its own strategy by means
they may have. In order to tackle these risks and to manage
related to intellectual property but also in the financial impact